In this article, Matteson Ellis and Leah Moushey describe the implications of the decision by the U.S. Department of Justice to link FCPA enforcement to interactions with cartels, transnational criminal organizations (TCOs), and Foreign Terrorist Organizations (FTOs). Addressing what this means in practice, they outline scenarios that companies could face that would implicate both Anti-Terrorism Act (ATA) and FCPA liability: "At first glance, the FCPA and ATA may appear to involve distinct risks: the FCPA targets bribery of foreign officials, while the ATA focuses on, among other things, the provision of material support to or aiding and abetting foreign terrorist organizations, or FTOs. In practice, however, these risks can converge — particularly in jurisdictions with high levels of FTO activity — creating overlapping exposure."